World of Service, Inc. - Page 4

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            In the early 1980s, Great's business area covered the States of           
          Florida, Georgia, and Alabama.  By 1982, Great was operating                
          (i.e., holding seminars) in about 26 States.  Throughout the                
          years in controversy, Service's principal place of business was             
          in the Johnsons' residence.  The Johnsons' residence, a three-              
          bedroom condominium, contained 1,600 square feet of usable space,           
          of which 320 square feet was used exclusively for Service's                 
          business purposes.  In addition, the Johnsons' two-car garage               
          contained 300 square feet, with an equal amount of attic storage            
          area above the garage.  Of the 600 total square feet of combined            
          garage area, 400 square feet was used exclusively for business              
          purposes.  The Johnsons' residential telephone was listed in                
          Service's name.  Service's checks contained the Johnsons'                   
          residence address.  During this period, Great had a separate                
          principal place of business and office in a commercial location             
          outside of the Johnsons' residence.                                         
            Service paid the Johnsons' residential mortgage payments of               
          $5,043 and $5,400 during 1982 and 1983, respectively.  Service              
          deducted $1,443 and $1,800 on its 1982 and 1983 income tax                  
          returns for use of the Johnsons' residence.  For those same                 
          years, the Johnsons reported $3,600 in income for Service's use             
          of the residence, because the mortgage was paid by Service.                 
          Respondent determined that only 10 percent of the residence was             
          used for business purposes and disallowed the mortgage and other            






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Last modified: May 25, 2011